ML19332F348
| ML19332F348 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/07/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-73817, NUDOCS 8912140303 | |
| Download: ML19332F348 (6) | |
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lb3 BALTIMORE
_ GAS AND CHARLES CENTER P. O. BOX 1475. BALTIMORE, MARYLAND 21203 i'
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December 7,1989 yc p Nwettan Entnoh s
.(300 260-4465
- U. S. ' Nuclear Regulatory Commission
. Washington, DC 20555 I
' ATTENTION:
Document Control Desk s.
Calvert Cliffs Nuclear Power Plant
SUBJECT:
. Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Reauest for Withholdine Information from Public Disclosure
REFERENCES:
(a)' Letter from Mr. S. A. McNeil (NRC) to Mr. G. C. Creel (BG&E),L dated November 28, 1989, " Denial of Request for. Withholding Information from Public Disclosure (Unit 2 TAC-73817)"
(b) Letter from Mr. G. C. Creel (BG&E) to NRC Document Control Desk, dated November 3, 1989, " Submittal of Pressurizer Heater Sleeve Repair / Replacement Plan" t
- Gentlemen:
We have discussed Reference (a) with Babcock and Wilcox (B&W). They have provided some further -information which we and they hope will clarify. and help to resolve this-matter.. We believe this letter is.self-explanatory and a copy is attached.
L
'We want to resolve this matter quickly, as evidenced by our prompt reply to your-letter.
We inadvertently stamped the simplified drawing of the existing design as proprietary.
.To correct :this, we are enclosing a revised replacement page for Enclosure 2 of our p
. previous submittal, Reference (b).
' We h' ope that-with the attached information and the replacement drawing for the l
non-proprietary document, this matter can be closed in a mutually acceptable manner.
We recommend that members from the staffs of BG&E, B&W and NRC meet at the earliest possible time to resolve this issue of proprietary. information.
We understand there has been communication between J. M. Osborne, BG&E Licensing
. Engineer "and S. A. McNeil, NRC Project Manager, concerning an' additional affidavit.
We believe information contained in the attached letter satisfies your request for additional information and should eliminate the need for an additional affidavit.
Since no new proprietary information is :provided, the original affidavit should be sufficient.
8912140303 891207 dp PDR ADOCK 03000317 P
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Document Centr:1 Desk
. December 7,1989-r Page 2-o We want' to take this opportunity. to again propose a meeting in which BG&E and Babcock and Wilcox would.-meet. with your Staff to brief them on the repair and replacement status and plans. We would propose that this briefing be held within the next two l
weeks at the NRC's offices. B. S. Montgomery will contact S.
A. McNeil to arrange mutually acceptable dates and times for the two meetings we are proposing.
Should you have any further questions regarding' this matter, we will be pleased to discuss them with you.
Very truly yours, GCC/JMO/ dim Attachments I
cc:
D. A.- Brune, Esquire J. E.
Silberg, Esquire R. A.Capra, NRC S. - A.McNeil, NRC W. T. Russell, NRC J. E. Beall, NRC T. Magette, DNR 1
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' i 86WMICLEAR SERWCE COMPANY 3y7,g9 244 33se oig for,,e goog _
P.O. Box 10935
' Eo5pineertrup S Mont services Division '
November 29, 1989 Lynchburg. VA 24506-0935 Telephone: 804-385-2000 Telecopy: 804-385-3663 Mr. J. M. Osborne Baltimore Gas and-Electric Calvert Cliffs; Nuclear Power' Plant MD Rtes. 2&4 P. O.1 Box 1535 Lusby, MD_
20657 p
Subject:
Proprietary Classification
References:
- 1)
Letter from G.
C.
Creel to the NRC, dated November 3,
- 1989,
Subject:
Calvert Cliffs' Nuclear Power Plant Submittal of Pressurizer Heater Sleeve Repair / Replacement Plan, 2)
Letter from S.
A. McNeil (NRC) to G.
C.
- Creel, dated November 28, - 1989,
Subject:
Denial ' of '
Request for Withholding Information,
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Dear'Mr. Osborne:
Based upon_ conversations with the NRC Calvert Cliffs Project
- Manager, Mr.
S.
A.'McNeil, and-information. contained in Reference 2,--B&W believes that there has been some misunderstanding with regard L to its proprietary claim for the Calvert Cliffs Heater E
Repair : - and Replacement Plan document.
We - regret this.
- accepts - the responsibility for this misunderstanding and hopes that this.' letter:can expeditiously clarify this situation.
We have: reviewed information which we believe-to be typical _of i
that-provided by BG&E during the period from July to October 1989.
We continue to believe that our proprietary claim is justified, i
The following points should help to clarify the B&W position:
1.
The previously released BG&E information was of a
preliminary,.
tentative and partial nature.
The B&W information was final, integrated and complete.
In this particular.' case, the proprietary claim is based not only on the individual. details concerning the repair, but also the total integrated combinati'n of information.
2.
When B&W' submits a proprietary document, it has been our general _ practice recently to stamp each page of the document to alert the. reader - should the document be redistributed in sections - that there is proprietary information contained in the overall document.
This is done for the convenience of the recipients.
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,n-Mr. J. M.-Osborne JHT/89-244 November-29,- 1989 Page.2 l,
3.
B&W has proprietary agreements with BG&E.
This allows for i
free and open verbal and written communications.
At times during-our interactions with the utility, information may be provided which is-not explicitly identified as. proprietary.
.This may. occasionally.be discussed with the NRC Staff without realizing or considering that it is proprietary.
It is impractical to work otherwise.
We
- are, however, more cautious with information which is likely to be transmitted I
to the NRC because of the NRC obligation to distribute these-formal transmittals'to'the Public Document Room (PDR).
We were somewhat bothered to find a preliminary version of a drawing showing the. pressurizer sleeve configuration in the
_j PDR, but we realize the drawing was not stamped proprietary.
Therefore,. we understand how this might have
- happened, j
Inadvertent release,
- however, of an isolated part of the i
total-document package does not diminish our proprietary-claim.
1 i
4.
The manner in which.the Repair and Replacement Plan (R&R) was 1
prepared may have contributed to the misunderstanding.
In an effort to expedite its transmittal to the NRC by BG&E, B&W
_l reviewed the final draft of the R&R Plan and marked'those i
. portions we considered to be proprietary.
The final typing and printing was performed by BG&E.
According to B&W guidance, BG&E stamped the proprietary version prior to its l
transmittal to the NRC.
This involved stamping every page of the document.
The stamping of the page showing the " existing design" was incorrect since -it is clearly not B&W j
proprietary.
It should be noted that this particular page l
was' simply stamped " Proprietary" and not "B&W Proprietary".
1 It may be appropriate to include this figure in the non-proprietary version o f.
the report.
This could easily be accomplished with a single page replacement to the previous transmittal.
B&W believes that free and open communication with the NRC Staff is very important and must not be unduly constrained by concerns about proprietary information.
Over the years, B&W has released large amounts of proprietary information to the NRC.
Much of this information relates to B&W's special expertise in materials and metallurgy.
There have been no problems related to an abuse of the proprietary classification.
In the particular case of the Calvert Cliffs R&R Plan document, we understand how a misunder-standing might have occurred and that is regrettable.
We remain convinced, however, that B&W's proprietary claim is appropriate and request that BG&E provide the information contained in this J
c.
l Mr. J. M. Osborne JHT/89-244 November 29, 1989
-Page-3 letter to the NRC.
We also request that BG&E have, the NRC reconsider the position they have taken in. Reference 2 in light of the above information.
We definitely believe that this issue-should not represent. an obstacle to near-term dialogue between the NRC and BG&E and B&W such that the NRC is not adequately
-informed about the R&R status and plans in a timely manner.
1 We would be happy to discuss this matter further with you or i
others at BG&E and/or the NRC.
V y truly yours, f
O j
J. H.
Tay Manager Licensing Services i
JHT/bcc cc:-
J.
R.
Bohart C.
W.
Carr D. J.
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ATTACHMENT (2)
Existing Heater Sleeve Design L
Configuration i
i Heater Sleeve
- Structural Weld I
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4 Heater Sleeve
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N Heater Sleeve i
Weld Collar
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